Text

TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco.
	ML051860296
Person / Time
Issue date:	06/20/2005
From:	Crowthers M, Infanger P, Sparkman W, Woods B; Technical Specifications Task Force
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-05-10 TSTF-439, Rev 2, WOG-165, Rev 0
	Download: ML051860296 (124)
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TECI-INICAL SPECIFICATIONS TASK FORCE TSTF A JoLTr 0 wVZrEreS G1OIJP A C7V7TY June 20, 2005 TSTF-05-1 0 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO"

Dear Sir or Madam:

Enclosed for NRC consideration is Technical Specification Task Force Traveler TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO." This revision addresses NRC comments.

We request that NRC review of the Traveler continue to be granted a fee waiver pursuant to the provisions of 10 CFR 170.1 1. Specifically, the request is to support NRC generic regulatory improvements (risk informed technical specifications), in accordance with 10 CFR 170.1 l(a)(1)(iii). This request is consistent with the NRC letter to A. R. Pietrangelo on this subject dated January 10, 2003.

Should you have any questions, please do not hesitate to contact us.

Michael Crowthers (BWROG)

P I4 Brian Woods (WOG/CE) Paul Infang BWOG)

Enclosure cc: Thomas H. Boyce, Technical Specifications Section, NRC lBWRl 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 OWNERs'GROUP Email: tstf@excelservices.com Owners GroupI Administered by EXCEL Services Corporation Q014

WOG-165, Rev. 0 TSTF-439, Rev. 2 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO NUREGs Affected: it 1430 WJ 1431 E! 1432 [./ 1433 Wj 1434 Classification: 1)Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Exempt Benefit: Prevents Unnecessary Actions Industry

Contact:

Wes Sparkman, (205) 992-5061, wasparkmesouthemco.com See attached justification.

Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: Wolf Creek Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 07-Feb-02 Owners Group Comments:

(No Comments)

Owners Group Resolution: Approved Date: 13-Feb-02 TSTF Review Information TSTF Received Date: 07-Feb-02 Date Distributed for Review: 13-Feb-02 OG Review Completed: i; BWOG i. WOG it CEOG ii BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 13-Feb-02 NRC Review Information NRC Received Date: 03-Jun-02 Final Resolution: Superceded by Revision Final Resolution Date: 04-Oct-02 20-Jun-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-165, Rev. 0 TSTF-439, Rev. 2 OG Revision RRvision Status: Closed R TSTF Revision I Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

TSTF-439 is revised. TSTF-439 deleted the last paragraph prior to the examples in Section 1.3. This paragraph states:

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery. . ." Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

Upon further consideration, the TSTF determined that all but the last two sentences of the paragraph should be retained. The discussion of "once per" Completion Times and of "from discovery" Completion Times is still applicable after implementation of this change. This change only deletes second Completion Times in a Condition that limit the maximum time an LCO can not be met. This type of condition is illustrated in Example 1.3-3, which is deleted by this change. The reference in the above paragraph to Example 1.3-3 must also be deleted. NUREG-1433 and 1434 contain single Completion Times based on failure to meet the LCO (for examples, see NUREG-1433 Required Actions of 3.3.5.1, 3.3.5.2, 3.3.7.1, and 3.4.2.) These Completion Times are unaffected by this proposed change and are described by the subject paragraph in Section 1.3.

To clarify the purpose of the change, the title is changed of TSTF-439 is changed from, "Eliminate Modified Time Zero Completion Times," to "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO."

The third paragraph of Section 1.0, Description, is added to include a discussion of the NRC's letter of September 10, 2002 which states that TSTF-430, "AOT Extension to 7 Days for LPI and Containment Spray (BAIW-2295-A, Rev. I)" cannot be approved because it modifies a second Completion Time based on time of discovery of failure to meet an LCO. This is consistent with the discussion of the NRC's disposition of TSTF-417 and TSTF409 in TSTF-439.

(Note: the NRC subsequently approved TSTF-430 and TSTF-409 with the originally proposed extensions of the the second Completion Times limiting time from discovery of failure to meet an LCO.)

TSTF Review Information TSTF Received Date: 04-Oct-02 Date Distributed for Review: 04-Oct-02 OG Review Completed: i; BWOG i; WOG ii CEOG Ed; BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 21-Oct-02 NRC Revicw Information NRC Received Date: 25-Oct-02 NRC Comments: Date of NRC Letter: 03-Mar-03 20-Jun-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-165, Rev. 0 TSTF-439, Rev. 2 TSTF Revision 1 Revision Status: Closed 3/3/03 - NRC provides letter requesting additional information.

TSTF439 proposes to make changes to standard technical specifications (NUREGs 1430 through 1434) associated with all Nuclear Steam Supply System Vendor design LCO that contain second completion time limits, those completion times that reference the maximum time allowed during any single contiguous occurrence of failing to meet the LCO. For all STS NUREGs the affected specifications include LCO 3.8.1, AC Sources - Operating, and LCO 3.8.9, Distribution Systems - Operating. For BWOG, CEOG and WOG STS the affected specifications also include -LCO 3.6.6, Containment Spray and Cooling Systems, and LCO 3.7.5, Auxiliary [Emergency] Feedwater System. For BWR/4 and BWR/6 STS the affected specifications also include LCO 3.1.7, Standby Liquid Control System.

The existing guidance for 10 CFR 50.65(a)(4) is not specific enough to ensure that all licensee programs for structure, system and component unavailability monitoring (Maintenance Rule) will assess and manage cumulative risk concerns regarding second completion time limits. This is because not enough overlap between the maintenance rule, TS, and the configuration risk management program exists to presume these operational limits would be managed by the associated system unavailability monitoring programs required by 10 CFR 50.65(a)(4).

Since TSTF439 proposes to delete second completion time limits in their entirety, replacing them with unavailability monitoring programs required by 10 CFR 50.65(a)(4), the staff requests additional information to show that unavailability monitoring programs required by 10 CFR 50.65(a)(4) will result in appropriate operational limits and appropriately manage cumulative risks during second completion time limits. Provide a qualitative analysis which explains how the 10 CFR 50.65(a)(4) monitoring program will manage the same kind of limits that exist in standard technical specifications that are proposed for elimination. Discuss the quantitative approaches envisioned as required to support the risk analysis in the 10 CFR 50.65(a)(4) program.

9/23/03 - A series of discussions between the TSTF and the NRC resulted in an agreement to revise TSTF-439 to eliminate the second completion times limiting time from discovery of failure to meet an LCO and to revise (not delete) ISTS Example 1.3-3 to discuss that "flip flopping" between Conditions without meeting the LCO is inapproprate and licensees should establish administrative controls to avoid it.

Final Resolution: Superceded by Revision TSTF Revision 2 Revision Status: Active Revision Proposed by: TSTF Revision

Description:

TSTF439 is revised based on discussions with the NRC. The changes are:

- Remarked pages on Revision 3 of the ISTS NUREGs.

- Retained Example 1.3-3. Revised the Actions to eliminate the second Completion Times limiting the time from discovery of failure to meet the LCO.

- Revised the Example 1.3-3 discussion to state that repeatedly moving from Condition to Condition without meeting the LCO is inappropriate and licensees should establish administrative controls to prohibit the practice

- Revised the justification to reflect these changes and to expand the discussion based on the extensive discussions held with the NRC on this matter.

TSTF Review Information TSTF Received Date: 18-Mar-05 Date Distributed for Review: 18-Mar-05 OG Review Completed: LR; BWOG EZJ WOG L% CEOG EL&BWROG 20-Jun-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-165, Rev. 0 TSTF-439, Rev. 2 VOG-I 65, Rev. 0 TSTF-439, Rev. 2 TSTF Revision 2 FRevision Status: Active TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 20-Jun-05 NRC Review Information NRC Received Date: 20-Jun-05 Affected Technical Specifications 1.3 Completion Times Action 3.1.7.B Bases SLC System Action 3.8.1A AC Sources - Operating Action 3.8.1 A Bases AC Sources - Operating Action 3.8.1.B AC Sources - Operating Action 3.8.1.B Bases AC Sources - Operating Action 3.8.9A Distribution Systems - Operating Action 3.8.9A Bases Distribution Systems - Operating Action 3.8.9.B Distribution Systems - Operating Action 3.8.9.B Bases Distribution Systems - Operating Action 3.8.9.C Distribution Systems - Operating Action 3.8.9.C Bases Distribution Systems - Operating Action 3.6.6A Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.6.6A Bases Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.6.6.C Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.6.6.C Bases Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.7.5A EFW System NUREG(s)- 1430 Only Action 3.7.5A Bases EFW System NUREG(s)- 1430 Only 20-Jun-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-I165, Rev. 0 TSTF-439, Rei v.2 Action 3.7.5.B EFW System NUREG(s)- 1430 Only Action 3.7.5.B Bases EFW System NUREG(s)- 1430 Only Action 3.7.5.B Bases AFW System NUREG(s)- 1431 1432 1433 1434 Only Action 3.6.6BA Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6AA Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6AA Bases Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6BA Bases Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6B.B Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6B.B Bases Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6A.C Containment Spray and Cooling Systems (Atmospheric; and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6A.C Bases Containment Spray and Cooling Systems (Atmospheric. and NUREG(s)- 1431 1432 Only Dual)

Action 3.7.5.A AFW System NUREG(s)- 1431 1432 Only Action 3.7.5A Bases AFW System NUREG(s)- 1431 1432 Only Action 3.7.5.B AFW System NUREG(s)- 1431 1432 Only Action 3.1.7.A SLC System NUREG(s)- 1433 1434 Only Action 3.1.7.A Bases SLC System NUREG(s)- 1433 1434 Only Action 3.1.7.B SLC System NUREG(s)- 1433 1434 Only 20-Jun-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-439, Rev. 2

1.0 DESCRIPTION

In the Improved Standard Technical Specifications (NUREGs 1430 through 1434) (ISTS) a second Completion Time was included for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO.

These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AND" logical connector to the Condition-specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the ACTIONS for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

The proposed Traveler deletes these second Completion Times from the affected Required Actions. It also revises ISTS Example 1.3-3 to remove the second Completion Times and to revise the discussion in that Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the Completion Times and is inappropriate. Therefore, the licensee shall have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO is not inappropriately extended.

2.0 PROPOSED CHANGE

NUREG-1430 ISTS Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6 Required Actions A.1 and C.1, Technical Specification 3.7.5 Required Actions A.1 and B.1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A.1, B.l, and C.1 is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

NUREG-1431 andNUREG-1432 ISTS Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6A Required Actions A.l and C.1, Technical Specification 3.6.6B Required Actions A.I and B.l, Technical Specification 3.7.5 Required Actions A.I and B.l, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A.1, B.1, and C.1 is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

NUREG-1433 and NUREG-1434 ISTS Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.1.7 Required Actions A.l and B.1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A.1, B.l, and C.l is being deleted. The Bases associated with these Required Actions are also being revised to delete Page 1

TSTF-439, Rev. 2 the discussion of the second Completion Time.

3.0 BACKGROUND

Between July and December of 1991, the NRC and the ISTS lead plants discussed an issue affecting a small number of Technical Specifications that could theoretically allow indefinite operation of the plant while not meeting an LCO.

Put simply, if an LCO requires OPERABILITY of two systems, it is possible to enter the Condition for one inoperable system and before restoring the first system, the second system becomes inoperable. With the second system inoperable, the first system is restored to OPERABLE status. Before restoring the second system, the first system becomes inoperable again, and so on. Under this scenario, it would be theoretically possible to operate indefinitely without ever meeting the LCO. This also could occur with LCOs which require one only system to be OPERABLE, but for which the Conditions describe two or more mutually exclusive causes of inoperability.

An NRC internal memo dated August 5, 1991 described the issue. As stated in the memo, "In these Specifications the following phrase was added in the Completion Time column of the Conditions that could extend the AOT: '[10 days] from discovery of failure to meet the LCO.' The [10 day] Completion Time cap is found by adding the maximum Completion Times from the two Conditions that could extend the AOT."

The decision to add the second Completion Time is summarized in a memo from the NRC to the industry lead plant representatives dated December 16, 1991. Both memos are attached.

It is important to note that this issue of "flip flopping" between Conditions only applies if the LCO is not met. If the LCO requirements are met, even if for an instant, this issue does not occur. This is a highly unlikely scenario and the Industry argued that it would never occur, but the NRC believed it should be addressed when developing the ISTS because there were no other regulatory processes in place at that time which could prevent or respond to such a situation, should it occur.

Section 1.3 of the ISTS, Example 1.3-3, describes the use of this type of second Completion Time. The ISTS NUREGs contain these types of second Completion Times in the following Specifications:

AC Sources - Operating (BWRs and PWRs)

Distribution Systems - Operating. (BWRs and PWRs)

Containment Spray and Cooling (PWRs)

Auxiliary / Emergency Feedwater System (PWRs)

Standby Liquid Control (SLC) System (BWRs)

The addition of these second Completion Times did not originally create an operational restriction because the likelihood of experiencing concurrent failures such that the second Completion Time is limiting is very remote.

However, these second Completion Times became a problem when the Industry proposed risk-informed Completion Times for some of the Specifications which contained the second Completion Times.

Specifically TSTF-409, Containment Spray System Completion Time Extension (CE NPSD-I 045-A),

and TSTF-430, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1). These Travelers extended a Completion Time and, following the methodology described in the August 5, 1991 memo, the second Completion Time was extended by the same amount (i.e., the second Completion Time continued to be the sum of the two Completion Times.) However, in letters to the TSTF dated November Page 2

TSTF-439, Rev. 2 15, 2001 and September 10, 2002, the NRC stated that the extension of the second Completion Time in TSTF-409 and TSTF-430 was inappropriate because one of the two Completion Times added to obtain the second Completion Time limit was risk based and the other was deterministic. On September 10, 2002, the NRC provided a letter making a similar statement regarding TSTF-430. Eventually, the NRC accepted that it was acceptable to add these two Completion Times and TSTF-409 and TSTF-430 were approved. However, second Completion Times complicate the presentation of the ISTS and complicate the implementation of risk-informed Completion Times. In addition, other regulatory requirements, not present when the ISTS NUREGs were originally developed, eliminate the need for these second Completion Times.

4.0 TECHNICAL ANALYSIS

The adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the Technical Specifications. However, that is no longer the case. There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.

The Maintenance Rule: 10 CFR 50.65 (a)(1), the Maintenance Rule, requires each licensee to monitor the performance or condition of SSCs against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC Resident Inspectors monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65 (a)(l) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the ACTIONS of the Technical Specifications and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65 (a)(3).

Under the Technical Specifications the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same LCO. However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-0 1, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. This Page 3

TSTF-439, Rev. 2 comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the Technical Specifications.

Thie Reactor Oversight Process: NEI 99-02, "Regulatory Assessment Performance Indicator Guideline,"

describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by RIS 2001-11, "Voluntary Submission Of Performance Indicator Data." NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs), and the Auxiliary feedwater system. Extended unavailability of these systems due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the ROP.

In addition to these programs, a requirement is added to Section 1.3 of the Technical Specifications to require licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This Technical Specification requirement, when considered with the regulatory processes discussed above, provide an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.

Each of the Specifications affected by this Traveler are discussed below.

AC Sources - Operating(B YRs and PWRss)

Specification 3.8.1, AC Sources - Operating, has a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one offsite circuit inoperable (Condition A) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one diesel generator inoperable (Condition B). Both Condition A and Condition B have a second Completion Time of "6 days from discovery of failure to meet the LCO." The second Completion Time limits plant operation when Condition A or B is entered, and before the inoperable system is restored, the other Condition is entered, and then the first inoperable system is restored, and before the remaining inoperable system is restored, the other Condition is entered again. This highly improbable scenario is further limited by Condition D wvhich applies when an offsite circuit and a DG are inoperable. It limits plant operation in this Condition to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . See Example I for an illustration.

Time = 0 Limited by second Completion Time to 6 days a Less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Diesel Inoperable Diesel Inoperable Condition A I Condition A II_ be less than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by Condition D I l Offsite Circuit Inoperable l I s Condition B Less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Example 1 Page 4

TSTF-439, Rev. 2 As stated above, the Reactor Oversight Process monitors the availability of mitigating systems, including the emergency AC sources (DG unavailability). Such frequent, repeated failures of the AC sources would be reported to the NRC and this represents a strong disincentive to such operation.

DistributionSystems - Operating (BJWRs andPJVTYs)

Specification 3.8.9, Distribution Systems - Operating, has an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for one or more AC electrical power distribution subsystems inoperable (Condition A), and a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for one or more AC vital buses (Condition B) or one or more DC electrical power subsystems (Condition C) inoperable . Conditions A, B, and C have a second Completion Time of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. Condition E applies if two or more electrical distribution subsystems are inoperable and, if it results in a loss of safety function, LCO 3.0.3 must be entered immediately. See Example 2.

Time =0 Limited by second Completion Time to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months i I Less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AC subsystem inoperable AC subsystem inoperable Condition A Condition A X Inoperabilities must overlap. Ifloss of safety function, enter LCO 3.0.3 I Vita inaCle immediately by Condition E inoperable

! Condition B e

or DC than2 subsystem hours inoperable hours Condition c Example 2 The second Completion Time is not needed. First, it is unusual for an AC electrical power subsystem or AC vital bus to be inoperable without causing a reactor trip. Secondly, Completion Times are very short (8 and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) providing little time to restore systems such that the Conditions overlap and multiple inoperabilities occur. Lastly, should any overlapping inoperabilities that result in a loss of safety function occur, a plant shutdown in accordance with LCO 3.0.3 is required.

Containment Spray and Cooling (PWVRs)

Specification 3.6.6A, Containment Spray and Cooling Systems (Credit taken for iodine removal), has a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one containment spray train inoperable (Condition A) and a 7 day Completion Time for one containment cooling train inoperable (Condition B). Conditions A and B have a second Completion Time of 10 days from discovery of failure to meet the LCO. Condition F also states that if two containment spray trains are inoperable or any combination of three or more trains are inoperable, LCO 3.0.3 must be entered immediately. Specification 3.6.6B, Containment Spray and Cooling Systems (Credit not taken for iodine removal), has a 7 day Completion Time for one containment spray train inoperable (Condition A) and a 7 day Completion Time for one containment cooling train inoperable (Condition B). Conditions A and B have a second Completion Time of 14 days from Page 5

TSTF-439, Rev. 2 discovery of failure to meet the LCO. Condition G also states that if any combination of three or more trains are inoperable, LCO 3.0.3 must be entered immediately. See Example 3 for an illustration of Specification 3.6.6A.

Time=O I Limited by second Completion Time to 10 days I 1<

I Less than 7 days Less than 7 days A<

One containment cooling train One containment cooling train inoperable inoperable Condition C Condition C I I 0- 01 Inoperabilities must overlap. If any combination of three or more trains, I One I enter LCO 3.0.3 immediately by I I containment -1 I Condition F I cznrqv trnin / 4---* I inoperable Less (Condition A) than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Example 3 The second Completion Time is not needed. Any combination of two of the four trains can perform the safety function. Adverse combinations require entry into LCO 3.0.3. The second Completion Time restricts operation with only one train inoperable, but that is unnecessary because when one train is inoperable, there are still three operable trains and only two trains are needed to perform the safety function. Therefore, the second Completion Time is overly restrictive.

Auxciliary / Emergetncy Feedwt~aterSystem (PWVRs)

Specification 3.7.5, Auxiliary Feedwater System (NUREG-1430 - Emergency Feedwater System) has a 7 day Completion Time for one inoperable steam supply to a turbine driven AFW pump (rendering the turbine driven AFW pump inoperable) (Condition A) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one AFW train inoperable (Condition B). Conditions A and B have a second Completion Time of 10 days from discovery of failure to meet the LCO. In order for the second Completion Time to be limiting, entry into and out of Conditions A and B must occur, which requires the turbine driven and motor driven AFW pumps to be concurrently inoperable. However, Condition C states that if AFW trains are inoperable the plant must be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . See Example 4.

Page 6

TSTF-439, Rev. 2 Time=O I Limited by second Completion Time to 10 days:

Less than 7 days Less than 7 days One steam driven AFW train One steam driven AFW train inoperable inoperable Condition A Condition A l X must overlap. l One motor tdriven AFW tnprable / trains inoperable requires Condition B than 72 immediate shutdown by Condition C hours Example 4 The second Completion Time is not needed. For the second Completion Time to be limiting, Conditions A and B must be entered concurrently. However, Condition C requires an immediate shutdown when two trains are inoperable. Therefore, the second Completion Time will never be limiting and can be removed.

In addition, the Reactor Oversight Process monitors the availability of the AFW system. Such frequent, repeated failures of the AFW system would be reported to the NRC and this represents a strong disincentive to such operation.

Standby Liquid Control (SLQ System (BJWRs)

Specification 3.1.7, Standby Liquid Control has a 7 day Completion Time for one inoperable SLC subsystem (Condition B) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for the boron concentration of the boron solution storage tank not within limits (Condition A). The boron solution storage tank is shared by both SLC trains. Conditions A and B have a second Completion Time of 10 days from discovery of failure to meet the LCO. See Example 5.

Page 7

TSTF-439, Rev. 2 I Time=0 I I Limited by second Completion Time to 10 days:

I Less than 7 days Less than 7 days a No--

One SLC subsystem One SLC subsystem inoperable inoperable Condition A Condition A Boron concentration not within limit but greater than cold shutdown value.

Otherwise Les immediate than 72 shutdown under hours LCO 3.0.3 Example 5 The second Completion Time is not needed. There are other similar specifications which provide for the parameters of a common tank to be inoperable (for example, PWR Refueling Water Storage Tank) which do not employ a second Completion Time. There is also no significant safety concern. As stated in the Bases, when in Condition A the SLC systems are capable of performing their original design basis function and the SLC system capability still exists for vessel injection. Therefore, the second Completion Time is overly conservative and not required.

In addition to these regulatory programs, Section 1.3 of the Technical Specifications is revised to require administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

Based on the above discussions, the concern regarding multiple continuous entries into Conditions without meeting the LCO is addressed by the system unavailability monitoring programs described above and the administrative controls required by Section 1.3 of the Technical Specifications. Therefore, this potential concern is no longer an issue and the Technical Specifications can be simplified by eliminating the second Completion Times with no detriment to plant safety.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration NUREG-1430, Standard Technical Specifications forBabcock & Wilcox plants, is modified. Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6 Required Actions A.1 and C.1, Technical Specification 3.7.5 Required Actions A.I and B.1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A.l, B.l, and C.I is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

Page 8

TSTF-439, Rev. 2 NUREG-1431 and NUREG-1432, Standard Technical Specifications for Westinghouse and Combustion Engineering plants, respectively, are modified. Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6A Required Actions A.I and C.1, Technical Specification 3.6.6B Required Actions A.I and B.1, Technical Specification 3.7.5 Required Actions A.1 and B.1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A.1, B.1, and C.1 is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

NUREG-1433 and NUREG-1434, Standard Technical Specifications for Boiling Water Reactors, BWR/4 and BWR/6 respectively, are modified. Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.1.7 Required Actions A.1 and B.1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A.1, B.l, and C.l is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes eliminate certain Completion Times from the Technical Specifications.

Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed changes do not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed changes are consistent with the safety analysis assumptions and resultant consequences.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Page 9

TSTF439, Rest. 2 The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The changes do not alter any assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined.

The safety analysis acceptance criteria are not affected by this change. The proposed changes will not result in plant operation in a configuration outside of the design basis.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, the TSTF concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements 10 CFR 50.36, "Technical Specifications." 10 CFR 50.36(c)(2) states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." The revised Actions continue to meet the requirements of this regulation.

10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 10

TSTF-439, Rev. 2

7.0 REFERENCES

1. Memorandum from Gordon Vytlacil (NRC) to TSPS (NRC), dated August 5, 1991, "Summary of potential Allowed Outage Time (AOT) extension issue."

2. Gordon M. Vytlacil (NRC) to Lee Bush (WOG), et al, dated December 16, 1991, "Information on the Completion Time Cap - to be discussed at Wednesdays meeting with Chris Grimes."

Page I 1

TSTF-439, Rev. 2 INSERT It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO.

These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ." Example 1.3 3 illustrates one usc of this type of Completion Time. The 10 day Completion Timc specified for Gonditions A IdB in CEnpl 1.3 3 mnay not bc extcdndd.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

1.3-2 Rev. 3.0, 03131/04 BWOG STS BWOG STS 1.3-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to OPERABLE train status. AND inoperable.

10 days f4m discovery of failure to meet the LCO B. One B.1 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train to OPERABLE train status. AtN inoperable.

10 days from discovery of failure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X train to OPERABLE train status.

inoperable.

OR AND C.2 Restore Function Y One train to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y status.

train inoperable.

.3-5Rev 3.0 03/1/0 BWOGSTS BWOG STS 1.3-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and B are modified by a logical coennector, with a separatc 10 day Completion Time m~easured fromR thc time it waG discovered the LCO was not met. In this example, without the ceparatc Completion Tim iold ic possible to alternate betwccn Conditions A, B, and C in cuch a manner that operation could continue indefinitely without cver rcstoring systems to meet the LCO. The separate Completion Timc modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time Ozro" for beginning the Completion Time "oc ek." in this instance, the Completion Time "time zero)" is specified as commencing at the time the LCO w.Vas initially not met, instead of at the time the associated Condition was entered.

INSERT 1.3-6 Rev. 3.0, 03/31/04 STS BWOG STS 1.3-6 Rev. 3.0, 03131/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3,and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray [7] days train inoperable. train to OPERABLE status.

AND

[I 4]days fFGM discovery of failure to meet the LCO B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months C. One [required] C.1 Restore [required] 7 days containment cooling containment cooling train to train inoperable. OPERABLE status. AND

[I44 days fFGM discovery of failure to meet the LCO BWOG STS 3.6.6-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 EFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Emergency Feedwater (EFXN) System LCO 3.7.5 [Three] EFW trains shall be OPERABLE.

- --- -------- - ------ - ---- NoOTE--

Only one EFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

- ------- -NOTE---

LCO 3.0.4.b is not applicable when entering MODE 1.

CONDITION REQUIRED ACTION COMPLETION TIME A. [ One steam supply to A.1 Restore affected equipment 7 days turbine driven EFW to OPERABLE status.

pump inoperable. AND OR 10 days from discovery of failurc to meetthe LGO]

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven EFW pump inoperable in MODE 3 following refueling.

BWOG STS 3.7.5-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 EFW System 3.7.5 ACTIONS (continued) o CONDITION REQUIRED ACTION COMPLETION TIME B. One EFW train B.1 Restore EFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable [for reasons OPERABLE status.

other than Condition A] AND in MODE 1, 2, or 3.

[10 days from discovery of failure to meet the IL, C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND

[or B] not met.

C.2 Be in MODE 4. [18] hours

[ OR Two EFW trains inoperable in MODE 1, 2, or 3. ]

D. [Three] EFW trains D.1 ------------NOTE---

inoperable in MODE 1, LCO 3.0.3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one EFW train is restored to OPERABLE status.

Initiate action to restore Immediately one EFW train to OPERABLE status.

E. Required EFWtrain E.1 Initiate action to restore Immediately inoperable in MODE 4. EFW train to OPERABLE status.

BWOG STS 3.7.5-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 6 days from discovery of failure to meet LCO B. One [required] DG B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE [required]

offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours DG(s) is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s).

AND BWOG STS 3.8.1-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND 6 days from discovry' of failure to meet LCO C. Two [required] offsite CA Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

D. One [required] offsite -------------NOTE-----------------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any train.

inoperable. _ ______ _-_-

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

BWOG STS 3.8.1-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1,2,3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC -----------NOTE ---------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status. AND 16 heurs from discovery of failure to Feet LGO B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses inoperable. subsystem(s) to OPERABLE status. AND 46 h9ufroUGm discovery of failure to meet LGO BWOG STS 3.8.9-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power power distribution distribution subsystems subsystem(s) to AND inoperable. OPERABLE status.

1 -h9Ur6 frGm discovery of failure to meet LGG D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, and AC vital bus electrical power distribution subsystems.

BWOG STS 3.8.9-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS A.1 With one containment spray train inoperable, action must be taken to restore it to OPERABLE status within [7] days. In this condition, the remaining OPERABLE containment spray train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure to the remaining containment spray train could result in loss of spray function. The [7] day Completion Time is reasonable to perform corrective maintenance on the inoperable containment spray train. The [7] day Completion Time is based on the findings of the deterministic and probabilistic analysis in Reference 5. Reference 5 concluded that extending the Completion Time to [7] days for an inoperable containment spray train proves plant operational flexibility while simultaneously reducing overall plant risk. This is because the risks incurred by having the containment spray train unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during plant shutdown operations.

The [14] day portion of the Completion Time for Required Action AA.1 is based uponeninoloran judgment. it takveainto account the lowv' probability of coincident cntry into two Gonditions in this LCOGoupled with the low probability of an accident tourinRg durring this tiol. Refer to Section 1.3, Complctien Times, for a more detailcd discucSion of the purpose of the "from disecvciy; of failure to meet the LCO" portion of the Completion Time.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time to attempt restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

3..6-5Rev.3.0 0311/0 BWOGSTS BWOG STS B 3.6.6-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS (continued)

C.1 With one of the required containment cooling trains inoperable, the inoperable containment cooling train must be restored to OPERABLE status within 7 days. The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

The [11] day portion of the Completion Time for Required Action C.1 is based upon judggeneerigudmt. it takes into aoGunt the low probability of coincident ntry into two Conditiens in this LCO coupled with the lowAv probability of an ac;idont occurring during thic time. Refer to Section 1.3 for a more detailed discussion of the purpose of the "from discovery of failure to meet the LCO" portion of the Completion Time.

D.1 and D.2 With one containment spray and one [required] containment cooling train inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.

E.1 With two of the required containment cooling trains inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition (both spray trains are OPERABLE or else Condition G is entered) provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

Rev. 3.0, 03/31/04 STS B 3.6.6-6 BWOG STS BWOG B 3.6.6-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 EFW System B 3.7.5 BASES ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable EFW train when entering MODE 1. There is an increased risk associated with entering MODE 1 with EFW inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

[A.1 With one of the two steam supplies to the turbine driven EFW pump inoperable, or if a turbine driven pump is inoperable while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven EFW pump, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump.

b. For the inoperability of a turbine driven EFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

c. For both the inoperability of a steam supply line to the turbine driven pump and an inoperable turbine driven EFW pump while in MODE 3 immediately following refueling, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven EFW pumps, and due to the low probability of an event requiring the use of the turbine driven EFW pump.

The second Complotion Timo for Required Action A.1 establishes a limit on the mnximum llo ted frr atim eom binatien of Conditions to be inoperabl during any continuous failurp to meet this ___.

The 10 daiy Completion Time prOvidcs a limitation timc allowed ir this specified Condition after discovery of failure to meet the LCO. This limit iq cnnnidercd red i r fhla A Pro for situations in wihish aondiftins A. -Rnd-ntered ourGrUFently. The AND conRnector betwe(a4n 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days 4

aictets that both Completion Times apply simultaa cously, and the more restrictive must be met.

S S 3 7. -4Re . .0 0 /3 /0 B WO BWOG STS B 3.7.5-4 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 EFW System B 3.7.5 BASES ACTIONS (continued)

Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling.

Condition A allows one EFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.]

B.1 When one of the required EFW trains (pump or flow path) is inoperable, action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to one of the turbine driven EFW pumps. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on the redundant capabilities afforded by the EFW System, time needed for repairs, and the low probability of a DBA occurring during this time period. The second Completion Time for Required Acton 814 establishes a limit en the mFaximum tkme allowed for any combination of Conditions to be inoperable during any continuous failure to mSeet this LGO.

The 10 day Completion Time provides a limitation time allowed in this A,^,;;A4 e -i+;^,. - .4;t.A a-Z ; L-s-- --- L 9AL I onr ThL-!- 1!-;&

5prebitieu l~tI A4A f rdtib A

Aty Ati faflut!P IrA1 kuA fft t_*lEat fi I

!~Fv5%ffm1{i-Laut is considered reasonable for situations in which Conditions A and B are entered cronurrently. The AND cronnector between 7-2 houry and 10 days dictates that both Completion Times apply simult:Bneously, and the more Feztictive murt b met.

C.1 and C.2 When either Required Action A.1 or Required Action B.1 cannot be completed within the required Completion Time, [or when two EFW trains are inoperable in MODE 1, 2, or 3,] the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within

[18] hours.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

B 3.7.5-5 Rev. 3.0, 03/31/04 BWOG STS STS B 3.7.5-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked, Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The ceondrG ComplPetion Timne for Required ActioR A.3 octabliche a limit on the maximum time allowed for any combination of required AC power courcer to be inrperable during any iRgle cnRtigueus occurraeRne o9 failing to meet the LCO. If Condition A is entered while, for instanee, a DG is inoperable and that DG is subsequently returned OPERABLE, the LGO may arleady have been Rnt met for Up to 72 hoUre. ThiS could lead Rev. 3.0, 03/31/04 STS B 3.8.1-6 BWOG STS B 3.8.1-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) to a total of 111l hours, cince initial failure to moot the LCO, to restore tho offsito crciFt. At this time, a OG ould again bec)mo inobero, the circuit restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for a total o 0 day6) allowed prior t Gomplote reorteatioRn of the LO.n The 6 aya-Completion Timc provides a limit on the time allowed in a specified condition after discovery of faiure to meet the LCO. This limit is con;rsidered rasonrable for itu-tionsu in Which Conditions A and B are cntered concurrently. The AND connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 day Completion Times moans that both Completion Times apply cimultancously, and the more restrictive Completion Time must be met.

As in Required Action A.2, the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This; IwRoill result in establishinR the "time zer" at the time that the ICon was initially not met, instead of at the time Condition A was entered.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

REVIEWER'S NOTE------------------------ -

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

Rev. 3.0, 03/31/04 STS B 3.8.1-7 BWOG STS BWOG B 3.8.1-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Thc sonerd Completion Time for Rreqwied AiRn 1 cA etablishes a limit on the maximum time alloe-d-fpr or Any corn binaiRo of required AG power sources to be inoperable during any single contiguous occurrence of failing to mneet the LCO. if Condition B is entered while, for instane, an offcite circuit is inoperable and that circuit is subsequently restored B3.8.1-9 Rev. 3.0, 03/31/04 BWOG STS BWOG STS B 3.8.1-9 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

OPERABLE, the LCO may already have boon not met for up to 7-2 hour.

This could Icad to a total of 111 hours0.00128 days 0.0308 hours 1.835317e-4 weeks 4.22355e-5 months , cince initial failure to moot the LCO, to rezorc the DG. At this time, an offsite circuit could again become inoperablo, the DG restored OPERABLE, and an additional s72 heUr (for a total of 0 days) allowed prior te complete retoratioen of the LCO. The 6 day Completion Time provides a limit on time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonablc for situations in which Condition A and Condition B are entered conGurrently. The "AND" connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months aRd 6 day Completion Timec mcane that both Completion Timne apply simultaneoucly, and the more restrictive Completion Time must be As in Required Action B.2, the Completion Time allows for an exception to the normrFal "time zero for begiRning the allowed time "clock." This will result in establishing the "time zero" at the time that the LCO was initially not mnet, instead of at the time Cendition B was entered.

C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

BWOG STS B 3.8.1 -10 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train to the actions associated with taking the unit to shutdown within this time limit and

b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The seeord oempletion Time for Required Action AA establishes a limit on the maximum time allowed for any combination of required distribution cub systms to bc iop crable during any single coRtiguous ourrenoe of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inopcrable and subsequeRtl'- rFestored OPERA.BLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution restored OPERABLE. This could continue indefinitely.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitatioR en this potential to fail to mneet the LGO indefinitely.

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC trains made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

Rev. 3.0, 03/31/04 STS B 3.8.9-4 BWOG STS BWOG B 3.8.9-4 Rev. 3.0, 03131/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum time -loAWed for r ny Gebinatio of Of ra Fequired di Itibton subsystems to be inoperable during any cinge contiguous oecurrcncc ot f£iling to meet the ICon. if oendition B ientered while, for inct-one, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hourM. This could lead to a total ef10 hour cinc initial failUre of the LCo, to Fretore the vital bus distribution system. At this time, an AC train could again bcrome inope~rble, _.nd itl bu diStribUtion rFetorled OERABLE. Thic could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" or0FDC91lFlt19 tHy allEo)Wco OUuaeWiLm 6lCK. In rHi Will rFedu it establiShing the "time zero" at the time the LCO was initially not met,

- w ^.- *hy *ti.-.n P^-ltn- R u a-tr~ar Thya *t l.n h, o re-t^

T~ime is on acGeptable limitation on this potential to tall to meet the LUU

. .. . I .. . . .. . __

tel C.1 With one or more DC buses or distribution panels inoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the [required] DC buses and distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

BWOG STS B 3.8.9-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue,

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions to restore power to the affected train, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Completion Time for Required Action C 1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single Gcontigu9us eGGuFsense elI failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is iRnpeFable and subsequeRtly FetUrned OPERABLE, the LCG may already have been not mot for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could load to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months .in initial failure of the LCO, to restore the DG distribution system..At this time, an AC train could again become

..^_l -- no Mk e.-;ee; r .+ rrU MrDAMI r- -hrL- -. 1- -^a- -&!;r .

iHUnPtJorUiU dHU LA. UlAlUUlduH 1UbtW1UU WrIr-DLE. I illb bUblU bUHMLMU This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the Co*was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail teomet the LCO in1 defi 11nitely.l FEEV aA 1 1 d~1W~AIi V11T W 1A Rev. 3.0, 03/31/04 STS B 3.8.9-7 BWOG BWOG STS B 3.8.9-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery. . ." Examplo 1.3 3 illustrates one use ot this type of Complction Timc. Thc 10 day Compiction Timc specified for CGnditiens A and B i Example 41.3 3 mnay not bo extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

13-2Rev.3.0 03/1/0 WOG TS WOG STS 1.3-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to OPERABLE train status. AND inoperable.

10 days from discovery of fai!UFr9 to meet the LCO B. One B.1 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train to OPERABLE train status. A/ND inoperable.

4O-days4FGM discovery of failure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X train to OPERABLE train status.

inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months One train to OPERABLE Function Y status.

train inoperable.

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

1.3-6 Rev. 3.0, 03/31/04 WOG STS WOG STS 1.3-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry WeGRditGR-A)

The CompletiRnTimes of Conditions A and B are modified by a logiGal connecter with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the 6eparate Completion Time, it wold be possible to alternate betweeR Conditions A, B, and C in cuch a manner that operation could Gontinue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Complction Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Genditiomvas entered.

INSER 1.3-7 Rev. 3.0, 03/31/04 STS WOG STS 1.3-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.6A 3.6 CONTAINMENT SYSTEMS 3.6.6A Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit taken for iodine removal by the Containment Spray System)

LCO 3.6.6A Two containment spray trains and [two] containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1,2,3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. train to OPERABLE status.

AND 10 days frFo discovery of failure to meet the LCO B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months C. One [required] C.1 Restore [required] 7 days containment cooling containment cooling train to train inoperable. OPERABLE status. AND 10 days from discovery of fai!ure to meet the LCO D. Two [required] D.1 Restore one [required] 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment cooling containment cooling train to trains inoperable. OPERABLE status.

WOG STS 3.6.6A-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.6B 3.6 CONTAINMENT SYSTEMS 3.6.6B Containment Spray and Cooling Systems (Atmospheric and Dual (Credit not taken for iodine removal by the Containment Spray System)

LCO 3.6.6B Two containment spray trains and [two] containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 7 days train inoperable. train to OPERABLE status.

AND 14Adays4f~am discovery of faigure to meet the LGO B. One [required] B.1 Restore [required] 7 days containment cooling containment cooling train to train inoperable. OPERABLE status. AND discovery of Figure to Fneet the LOG C. Two containment spray C.1 Restore one containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months trains inoperable. spray train to OPERABLE status.

WOG STS 3.6.6B-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 [Three] AFW trains shall be OPERABLE.

N t- __ ______________

[ Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4. ]

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

____ -- ------------------- -NO t ________

LCO 3.0.4.b is not applicable [when entering MODE 1.J CONDITION REQUIRED ACTION COMPLETION TIME A. [ One steam supply to A.1 Restore affected equipment 7 days turbine driven AFW to OPERABLE status.

pump inoperable. AND OR 10 days from discovery of failure to mneet the 4G ]

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

WOG STS 3.7.5-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable in MODE 1, OPERABLE status.

2, or 3 [for reasons other AND than Condition A].

f1O-days fe~m discovery of failure to meet the LCO]

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Condition A AND

[or B] not met.

C.2 [Be in MODE 4. [18] hours ]

[OR Two AFW trains inoperable in MODE 1, 2, or 3. ]

D. [ Three] AFW trains D.1 ---- NOTE-----------

inoperable in MODE 1, LCO 3.0.3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore Immediately]

one AFW train to OPERABLE status.

E. Required AFW train E.1 Initiate action to restore Immediately inoperable in MODE 4. AFW train to OPERABLE status.

WOG STS 3.7.5-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 6 days from dicovoey' of failurm to meet LCO B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. [required] offsite circuit(s).

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B required redundant concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours DG(s) is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s).

AND WOG STS 3.8.1-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND 6 days from discover; of failure to meet LCO C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required features AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

D. One [required] offsite --- ------ NOTE------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any train.

inoperable. -- --- - - --- ---------_ --

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

WOG STS 3.8.1-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC ----- --- NOTE------ -

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status. AND 46 hours5.324074e-4 days 0.0128 hours 7.60582e-5 weeks 1.7503e-5 months from discovery of failure to meet LGG B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses inoperable. subsystem(s) to OPERABLE status. ANbD 16 heous from diScovery of failure to Meet-LGO WOG STS 3.8.9-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power power distribution distribution subsystems subsystem(s) to AND inoperable. OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovcryeof failurc to meetbLO D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, and AC vital bus electrical power distribution subsystems.

WOG STS 3.8.9-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES ACTIONS (continued)

The 10 day portion of the Completion Time for Required Action A.1 is based uponengineering judgment. It takes into acGount the low probability of coincident ent'y into two Conditions in this Specification coupled with the low probability of aR acideRnt occurring during this time-.

Refer to Section 1.3, "Completion Times," for a more detailed discussion of the purpose of the "frofm diScove; of fai!ure to mneet the LCO" peatieR of the Completion Time.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time for attempting restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

C.1 With one of the required containment cooling trains inoperable, the inoperable required containment cooling train must be restored to OPERABLE status within 7 days. The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of DBA occurring during this period.

The 10 day po~ien of the Completion Time for Required ActioR G.1 is based upon engin ering judgment. It takes into account the low probability of coincident ntry into two Conditions in this Specification roupled w.'ith the 18oW probability of an arccident 0ocrring during this tinme.

Refer to Section 1.3 far a more detailed discussion of the purpose of the "from discovery of failure to meet the LCO" portion of the Completion Time.

WO T .66- e.3.,0/10 WOG STS B 3.6.6A-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES LCO (continued)

Each Containment Cooling System typically includes demisters, cooling coils, dampers, instruments, and controls to ensure an OPERABLE flow path.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the containment spray trains and containment cooling trains.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the Containment Spray System and the Containment Cooling System are not required to be OPERABLE in MODES 5 and 6.

ACTIONS A.1 If one containment spray train is inoperable, it must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing at least 100% of the heat removal needs (for the condition of one containment spray train inoperable) after an accident. The 7 day Completion Time was chosen in light of the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of DBA occurring during this period.

The 11 day portion of the Completion Time for Required Action A.1 is based upon engineering judgment. It takes into account the low probability of coincident entry into two Conditions in this LCO coupled with the low probability of an accident occurring during this time. Refer to Section 1.3, Completion Times, for a more detailed discussion of the purpose of the "from dirsoVer; of failure to moot the ILCO" portion of the Completion Time.

B.1 If one of the required containment cooling trains is inoperable, it must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing at least 100% of the heat removal needs (for the Condition of one containment cooling train inoperable) after an accident. The 7 day Completion Time was chosen based on the same reasons as given in Required Action A.1.

B3.66B-5Rev.3.0 03/1/0 WOG TS WOG STS B 3.6.613-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES ACTIONS (continued)

The 11 day portion of the Complotion Time for Required Action 8.1 is based upon engineering judgment. It takes into account the low prFobability of coincident try into two Gnditions in this Specification coupled with the low probability of an accident occurring during this time.

Refer to Section 1.3 for a more detailed discussion of the purpese of the "from disovenry of failure to mneet the IL ' portion of the CwonpletioR C.1 With two of the required containment spray trains inoperable, one must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen in light of the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, reasonable time for repairs, and low probability of DBA occurring during this period.

D.1 and D.2 If one required containment spray train is inoperable and one of the required containment cooling trains is inoperable, the inoperable containment spray train or the inoperable containment cooling train must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as those given in Required Action C.1.

E.1 If two required containment cooling trains are inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as those given in Required Action C.1.

WOG STS B 3.6.613-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AFW Sysem B 3.7.5 BASES ACTIONS (continued)

c. For both the inoperability of a steam supply line to the turbine driven pump and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The second Completion Timc for Required Action A.4 establishes a limit or the maximumtimrnime allowed fFor on;corn nntin of ConditionG to be inoperable during any continuouS failurc to meet this LCO.

The 10 day Complction Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which onrditiens A a-n B-re entered concurrently. The AND connector between 7 days and 10 days dictates that -bot Completo Ts apply simultaneously, and the mra e restrictive must be met.

Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling.

Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.]

B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 [for reasons other than Condition A], action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on redundant capabilities afforded by the AFW System, time needed for repairs, and the low probability of a DBA occurring during this time period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combinati9on of Conditines to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time alloeved in this specified Condition after discovery of failure to meet the LCO. This limit is onsidered reasonablefeorsituationsinwhich onditions A ndl B Are entered concurrently. The AND oonnector between 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

B 3.7.5-5 Rev. 3.0, 03131/04 WOG STS WOG STS B 3.7.5-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Complction Timo for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC powor sourGes- t be inoperable during any single contiguous occurroneeot failing to meet the LCO. If Condition A is enteced while, for instance, a DG is inoporable and that DG is ubsoquontly rotFrnod OPER\ABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This could lead to a total of 111l hours, sinco initial failuro to moot tho LCO, to restore the offsite circuit. At this time, a DG could again bccome inoporable, the circuit restored OERE1ABLE, and an additional 72-hours (for-a-total ot Odays) allowed prior to Gomvpleto rostoratioR of tho ILoC. The 6 day Completion Timc provides a limit on the time allowed in a spccifiod B 3.8.1-6 Rev. 3.0, 03/31/04 WOG STS WOG STS B 3.8.1-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) condition after discovery of failure to moet the LCO. This limit is considered reasenable for situations in which ConditioRs A and B aoe entered concurrently. The "ANID" connector betwecn the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 day Completion Times moans that both Completion Timer apply simultancously, and the more restrictive Completion Time must be met.

As in Required Action A.2, the Completion Time allo's, forr an exGeptin to the normal "time zero" for beginning the allowed outage time "clock."

This will result in establishing the "time zero" at the time that the LCO wvas initially not maet, instead oaf at the time C-oditioR A was entered.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

REVIEWER'S NOTE--------------------

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.

B 3.8.1-7 Rev. 3.0, 03/31/04 WOG STS WOG STS B 3.8.1-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) failure is repaired, the common cause failure no longer exists, and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), (24] hours is reasonable to confirm that .the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Acton 1D1 establishes a limit on the maximum time allowed for any combination of required AC power ources to be inoperable duriRn aRy Girle contiguous ccGurrence et failing to meet the LCO. If Condition B is entered while, for instance, an Ffefsite circuit ic inoperabhle- and that circiFt is GubsequeRtly restored OPERABLE, the LCO may already have been not met for up to 7-2 hour This ceuld lead to a total of 1 4 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , since initial fai!Ure to meet the LCO, to restore the DG. At this time, an offsite circuit could again h . - Li..h thL- Me, .L. J...nDCDAr% ,r c ___4

....- a LUtCUUIU ImupuIJdhl., MU LUb [USIO1U JtrL , adi an UUak!ljioE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total Ef 9 days) alloewed prier to complete restoration of the LCO. The 6 day Completion Time provides a limit on time allowed in a specified cendition after disceyery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" conneter between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 day Completion Times mneans that both C-mpletien Times apply simultaneously, and the more restrictive Completion Time must be met.

B 3.8.1-9 Rev. 3.0, 03/31/04 WOG STS WOG STS B 3.8.1-9 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A. in Required A.ctln a.2, the Completion Timo allows for an exception to the normal "time zero" for beginning the allowed time "clock." This will result in establishing the "time zero" at the time that the LCO vwas initially not met, inctead of at the time Condition B was entered.

C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable and

b. A required feature is inoperable.

If at any time during the existence of Condition C (two offsite circuits inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

WOG TS B3.81-10Rev.3.0 03/1/0 WOG STS B 3.8.1 -10 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit and

b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The second Completion Time for Required Action A.1 eostablihes a limit on the maximum time allowed for any combination of required distribution subsystem to hbe moperable during anon single contiguouS OccUrencc of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequensty rFeztred OPERA.BLE, the LGO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 10 hur, cincc ini4tial failure of the LCO, to rFetere the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution restored OPERABLE. This could centinue indefinitely.

The Completion Time allows for an exception to the normal "time zero" for beginRing the allowed outage time "locrk." Thii "wilr-ut

-1 in tablishing the "time zero" at the time the LO wac initially Rnot met, inctead of the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is on acceptable limitation on this potentiol to foil to meet the ICOQ indefinitely.

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC trains made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

WOG STS B 3.8.9-4 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

The second Completion Timc for Required Action B.1 establishes a limit on the maximum allowcd for ony combination Of roguiroed diriutlik "

subsystems to be inoperable during any singlc contiguouS occurrcnce of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCG may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of I0 houe, c.inc initiol failure of tho LCD, to rFetO-r the vital bur, distribution system. At this time, an AC train could again become inoperable, and vital bus distribution restored OPERABLE. This could continuc indcfinitely.

This Complction Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establiching the "time crF" at the timo the ILG-0D was initially net met, instead of the time Condition B was enteced. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is on oGceptoble limitations on this poteRtial to fail to moot the ICDO in~definitely C.1 With one or more DC buses or distribution panels inoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the [required] DC buses and distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

B 3.8.9-6 Rev. 3.0, 03/31/04 515 WOG STS B 3.8.9-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue,

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The ccoend Cempletion Time For RcqUired Action G establishcs a lIMi on the maximum time allowed for any combination of required dirtribution subsystemsrrto 4be inop;erable dUerir aRee iRgrle GGrstigUOUS OGGUFenrra ad failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subcqueRtly rFeturned OPERABLE, the LCo mnay aready have been not met for Up t 8 hour6. This could lead to a total of 10 houare, cnc initial failUre of the LCO, to rectro the IDG diStribution "t this time, an AC train could again become Ayltem.

inoperable, and DC-distribution restored OPERA.BLE. This could continue indefinitely.

This Complction Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not mnet, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this poteRtial to fail to mneet the LCO indefiniely.

B 3.8.9-7 Rev. 3.0, 03/31/04 WOG STS WOG STS B 3.8.9-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ." Example 1.3 3 illustrates one use of this type of CompletioR Time. The 10 day ComrpietioR Time spcified for Condition- A and B in Example 1.3 3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

CE_ - e. .,0/10 _T CEOG STS 1.3-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to OPERABLE train status. AND inoperable.

10 days from discovory of failure to meet the LGO B. One B.1 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train to OPERABLE train status. AND inoperable.

10 days from discovery of failurc to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X train to OPERABLE train status.

inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months One train to OPERABLE Function Y status.

train inoperable.

1.3-5 Rev. 3.0, 03/31/04 STS CEOG STS 1.3-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and B arc modified by a logical connector, with a separate 10 day Complction Time measured from the time it was discocrsed the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a mnaRner that operatiR reouid continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time meodified by the phrase "frm disr"en ot failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Compietion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition; was entered.

INSERT 1.3-6 Rev. 3.0, 03/31/04 CEOG STS CEOG STS 1.3-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.6A 3.6 CONTAINMENT SYSTEMS 3.6.6A Containment Spray and Cooling Systems (Atmospheric and Dual)

(Credit taken for iodine removal by the Containment Spray System)

LCO 3.6.6A Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3, and [4].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray [7] days train inoperable. train to OPERABLE status.

AND 14 days-frem discovery of failure to meet the 4CO B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months C. One containment cooling C.1 Restore containment 7 days train inoperable. cooling train to OPERABLE status. AND 14 days from discovery of failure to meet the LGG D. One containment spray D.1 Restore containment spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and one containment train to OPERABLE status.

cooling train inoperable.

OR CEOG STS 3.6.6A-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.66 3.6 CONTAINMENT SYSTEMS 3.6.6B Containment Spray and Cooling Systems (Atmospheric and Dual)

(Credit not taken for iodine removal by the Containment Spray System)

LCO 3.6.6B Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3, and [4].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 7 days train inoperable. train to OPERABLE status.

A1ND 4-4 days foem discovery of failure to meet the 1GO B. One containment cooling B.1 Restore containment 7 days train inoperable. cooling train to OPERABLE status. AND 1A-4daysfe4Fe discovery of failure to meet the LCO C. Two containment spray C.1 Restore one containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months trains inoperable. spray train to OPERABLE status.

CEOG STS 3.6.613-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFVA) System LCO 3.7.5 [Three] AFW trains shall be OPERABLE.

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3,

[MODE 4 when steam generator is relied upon for heat removal].

ACTIONS

_ _ -------------------- N' DT LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. [ One steam supply to A.1 Restore affected equipment 7 days turbine driven AFW to OPERABLE status.

pump inoperable. AND OR 40 days from discovery of failure to meet the LCO]

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

CEOG STS 3.7.5-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFWtrain B.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable [for reasons OPERABLE status.

other than Condition A] AND in MODE 1, 2, or 3.

[10 days from discovery of failure to meet the CGq1 C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND

[or B] not met.

C.2 Be in MODE 4. [18] hours OR

[Two] AFW trains inoperable in MODE 1, 2, or 3. ]

D. [ [Three] AFW trains D.1 ----------- NOTE-----------

inoperable in MODE 1, LCO 3.0.3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately]

AFW train to OPERABLE status.

CEOG STS 3.7.5-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 6 days from discovery of fai!ure to meet LCO B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE [required]

offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours DG(s) is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s).

AND CEOG STS 3.8.1-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND 6 days from discovery of failure to meet LCO C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

D. One [required] offsite --------------- NOTE----

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any train.

inoperable. ---

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuits to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

CEOG STS 3.8.1-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1,2,3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC -------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to Fmeet-lGO B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses inoperable. subsystem(s) to OPERABLE status. AND 16 houFs from discovery of failure to meet LCO CEOG STS 3.8.9-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months DC electrical power power distribution distribution subsystems subsystem(s) to AND inoperable. OPERABLE status.

16-hours from discovery of failure to meet &GG D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, and AC vital bus electrical power distribution subsystems.

CEOG STS 3.8.9-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment cooling trains.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the Containment Spray and Containment Cooling systems are not required to be OPERABLE in MODES 5 and 6.

ACTIONS A.1

REVIEWER'S NOTE----

Utilization of the 7 day Completion Time for Required Action A.1 is dependent on the licensee adopting CE NPSD-1 045-A (Ref. 6) and meeting the requirements of the Topical Report and the associated Safety Evaluation. Otherwise, a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time applies.

With one containment spray train inoperable, the inoperable containment spray train must be restored to OPERABLE status within [7] days. In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions. The [7] day Completion Time takes into account the redundant heat removal capability afforded by the Containment Spray System, reasonable time for repairs, and the findings of Ref. 6.

The 14 day portion of the Completion Time for Required ActioR A4 in based upon engineering judgmcnt. It takc into account the low probability of coincident ontr; into two Conditions in this Specification coupled with the loW probability of an accident occurring during this time.

Refer to Section 1.3, "Completion Times," for a morne detailed discusieon of the purposo of the "from discovery of failure to meet the LCO" portion of the Completion Timer B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is B 3.6.6A-5 Rev. 3.0, 03/31/04 CEOG STS CEOG STS B 3.6.6A-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES ACTIONS (continued) reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time for the restoration of the containment spray train and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

C.1 With one required containment cooling train inoperable, the inoperable containment cooling train must be restored to OPERABLE status within 7 days. The remaining OPERABLE containment spray and cooling components provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

The 11 day portion of the Completion Timo for Required Action C.1 is based uponengineerin judgment. It takes into account the low probability of coincident entry into two Conditions in this Specification oGupled with the low probabirity ofan accident ocurring durFiRg thic time.

Refer to Section 1.3 for a more detailed discussion of the purpose of the "from disceyery of failure to meet the LCO" portion of the Completion Time.

D.1 and D.2 With one containment spray and one containment cooling train inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.

CEOGSTS 3.66A- Rev 3.0 03/1/0 CEOG STS B 3.6.6A-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES ACTIONS (continued)

Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

The 11 day portion of the Completion Time for Required Action A.1 is based uponeRnn eering judgment. It tkec into _Acrount the low probability of coincident entry into two Conditions in this Specification coupled with the low probability of an accident occurring during this time.

Refer to Section 1.3, "Complction Times," for a more detailed discussion of the purpose of the "from discovory of failure to meet the LCO" portion of the CompletioR Tinme B.1 With one required containment cooling train inoperable, the inoperable containment cooling train must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing greater than 100% of the heat removal needs (for the condition of one containment cooling train inoperable) after an accident. The 7 day Completion Time was developed based on the same reasons as those for Required Action A.1.

The 14 day portion of the Completion Time for Required Action 1.1 is based upon engineering judgment. It takes into account the low probability of oide cntr; ito two CeRditieSa iR this Specification coupled with the loW probability of an accident occurring during this time.

Rer tAorSctiRon 1.3 for a m detailed dicuccie of ree he pursp of the "from dicEovery of failure to meet the LCO" portion of the Completion C.1 With two required containment spray trains inoperable, one of the required containment spray trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing greater than 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

Rev. 3.0, 03/31/04 B 3.6.6B-5 CEOG STS STS B 3.6.613-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AFW System B 3.7.5 BASES ACTIONS (continued)

The second Complction Time for Required Action A. 1 establishes a limit on the maximum time allowed for any combination of Conditions to bo inoperable during any continuous failure to meet this LCO.

The 10 day Complction Timc pFroides a limitation time allowed in this specified Condition after discovory of failure to meet the LCO. This limit is considered reaSoRable for situatioRs iR which Conditions A aR B- re entered concurrently. The AND connector between 7 days and 10 days dictates that both Compietion Times apply cimultancously and the more rcStrictiev must bc met.

Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling.

Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.]

B.I With one of the required AFW trains (pump or flow path) inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. Two AFW pumps and flow paths remain to supply feedwater to the steam generators. The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allowed iR this specified Condition after discovery of failure to meet the LCO. This limit is Ronsidered reasoRable for situatioRs iR which eoRditioRs A and B are entered concurrently. The AND connector betwen 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Rev. 3.0, 03/31/04 STS B 3.7.5-5 CEOG STS B 3.7.5-5 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Completien Time for Recquied Acion A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to bo inoperable during any single contiguous occurrenc-e o failing to mneet the LCO. If Gendition A is cnitcrcd while, for inStance, a DG iv inoperable, and that DG is subsequently returned OPERABLE, the LO may already have been not mnet fer Up to 72 hoUr. This could lead to a total of 14i4 hours, cinco initial failure to meet the LCO, to restore the offsite crcruit. At this time, a DG could again beo noprable, the circuit restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total oa 9 days) allowed prier to complete restoration of the LCO. The 6 day Completion Time provides a limit en the time atllwed in a specified condition after discovery of failure to mneet the LCO. This limit is B 3.8.1-6 Rev. 3.0, 03/31/04 CECIG STS CEOG STS B 3.8.1-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) considered reasonable for situations in which Conditions A and B are RntrodAr concrrnRtly. Tho "AND"ronertor between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months And 6 day Complction Time means that both Completion Times apply cimultaneously, and the more restrictive Completion Time must be met.

As in Required Action A.2, the Completion Time allows for an exception to the normaltime ero- for begiRRiRng the allowed outage time "cl1ok."

This will result in establishing the "time zero" at the time that the LCO was initially net met, instead of at tho time Cronditin A was entered.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features with a train, redundant to the train that has an inoperable DG.

Rev. 3.0, 03/31/04 B 3.8.1-7 CEOG STS STS B 3.8.1-7 Rev. 3.0, 03131/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The second Completion Time for Rcquired Action 1.4 establishes a limit oe the maximum time allowed for any comnbination of required A poer courses to be inoperable during any single contiguous occurrenc ot faiflingto mo thol L .e If Condition B is enRtered whilo, for instaRo, aR offsite-iircuit is inoperable and that circuit is subsequently returned OPERABLE, the LCO msay already have boon Rot met fo Up pt72 Or houVrV.

This could load to a total of 44hourF, 1 sinco initial failure to moot the LCO, te reStore the DG. At this time, an effsite circuit could agin become inoperable, the DG restored OPERABLE, and an additional 72 heurs(for a total ef 0 days) allowed prior tW complete restoatlonef the LCO. The 6 day Completion Time provides a limit on time allowed in a specified condition after diccovr'y of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 day Completinr Times t both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

As in Required Action 8.2, the Completion Timc allows for an exception to the normal "time zero" for beginning the allowed time "clock." This will result in establishing the "timezerFo" at the time that the LCQ was initially net met, instead of at the time Condition B was entered.

CEOG STS B 3.8.1-9 Rev. 3.0, 03131/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued).

Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit and

b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

Thc second Complction Timc for Required Action A.1 establishes a limit Ar tho mEaimum time arll1wod f-r -ArycmbiRation Of required di fributinon subsystems to be inoperable during any single contiguous occurrenec of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , cince initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, a-rnd AC distribution restored OPERABLE. This could continue indefinitely.

The Completion Time allows for an exception to the normal "time zero" for beginning thc allowed outage time "clock." Thic Will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition A was entcred. Thc 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months CompletioR Time is an r _.t.,.

a1CCCPtaDIU "iimutitUH UH] tHli5 PEMItont

.- .. !I - - -. t.- Irn_

tO fall to moo-t iflO L'.AA=' 1HIfWIflhtOI. 1..

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC trains made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

CEOG STS B 3.8.9-4 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

The second CempletioR Time Far Required ActioR 12 establishes a limit on the maximum allowed for any combination of required distribution cubsystems to be inoperable during any singlc contiguous occurrence of failiRng to mAeet the LO. if ConditiRnB is eRtered while, for instanRe, an AC bus is inoperable and subsequently returned OPERABLE, the LCO mnay already have ben Rnot met for Up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This Gould lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the vital bus distributior syste At time, an AC train could again beaome inoperable, aRd vital bus distribution restored OPERABLE. CThis could continue indefinitely.

-This CompIetion Time allows for an exception to the normal "time zero" fOF beginRnig the allowe oute time "crlck." This WAill result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Coitiondi was B eRtered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO iFdefinitely.

C.1 With one or more DC buses or distribution panels inoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the [required] DC buses and distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

.,0/10 CEGSSB3896Rv CEOG STS B 3.8.9-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components which would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue,

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Complction Timc for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurFencc of failing to meet the LGO. if Conditin; G is entered vwhile, for instarne, ar AC bus is inoperable and subsequently returned UPERK\BLE, the LU may already have becn Rnt met for up to 8 heou. This nildlead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , sinco initial failure of the LCO, to restore the DC dictributieR system. At this time, an_AC tra;i AAuild again beomrre inoperable, and DC distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This Will result in establishing the "time zero" at the timne the LC was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acesptable limitation on this potential to fail to meet the LCO indefinitely.

CEOG STS B 3.8.9-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ." Example 1.3 3 illustrates one use ot this type of Completion Time. The 10 day Complction Time specified for Gonditions A and B in Example 1.3 3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

1.3-2 Rev. 3.0, 03/31/04 BWRI4 STS BWR/4 STS 1.3-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X subsystem to subsystem OPERABLE status. AS4 inoperable.

10 days from discovery of failure to meet the LCO B. One B.1 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y subsystem to subsystem OPERABLE status. AND inoperable.

-1 4days from discovery of fai!ure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X subsystem to subsystem OPERABLE status.

inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months One subsystem to Function Y OPERABLE status.

subsystem inoperable.

1.3-5 Rev. 3.0, 03131/04 BWR/4 STS STS 1.3-5 Rev. 3.0, 03/31104

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

The Cempletion Timcs of Conditions ,A; and B arc modified by a logical connector with a sceparate 10 day Complction Time measured from the time it was dicoere.ed the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery ot failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Timc allows for an exc;eption tothe norma!l "timezero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as comncn at the time the LGO was initially not met, instead of at the time the associated Condition was entered.

E+}ER 1.3-6 Rev. 3.0, 03/31/04 BWRI4 STS BWR/4 STS 1.3-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [ Concentration of boron A.1 Restore concentration of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in solution not within boron in solution to within limits but> [ l . limits. AND IQ days4frm discovcry of failure to meet the LCO ]

B. One SLC subsystem B.1 Restore SLC subsystem to 7 days inoperable [for reasons OPERABLE status.

other than Condition A]. A1ND

[10 days from discovery of failure to meet the 4Ol C. Two SLC subsystems C.1 Restore one SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable [for reasons subsystem to OPERABLE other than Condition A]. status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

BWR/4 STS 3.1 .7-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 6 days from discovery of failure to meet LCO B. One [required] DG B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE [required]

offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s), 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG, inoperable when the Condition B redundant required concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours DG(s) are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s).

AND BWR/4 STS 3.8.1-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND 6 days from discovery of failure to meet LCO C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when the discovery of redundant required Condition C feature(s) are inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

D. One [required] offsite circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any division.

inoperable.

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

E. Two [or three] [required] E.1 Restore one [required] DG 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months DGs inoperable. to OPERABLE status.

BWR/4 STS 3.8.1-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 [Division 1] and [Division 2] AC, DC, [and AC vital bus] electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC - ---- NOTE ------------

electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, "DC inoperable. Sources - Operating," for DC divisions made inoperable by inoperable power distribution subsystems.

A.1 Restore AC electrical power 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status. AND 16 hourGSfrm discovcry of failure to mneet LGO B. [One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months buses inoperable. distribution subsystem(s) to OPERABLE status. AND 16 hour- from discovery of failure to meet LGG ]

BWR/4 STS 3.8.9-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more [station C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months service] DC electrical power distribution power distribution subsystem(s) to AND subsystems inoperable. OPERABLE status.

46 houWs from discovery of failure to meet LCG D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. [ One or more DG DC E.1 Declare associated DG(s) Immediately]

electrical power inoperable.

distribution subsystems inoperable.

F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, [and AC vital bus] electrical power distribution subsystems.

BWR/4 STS 3.8.9-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 SLC System B 3.1.7 BASES LCO The OPERABILITY of the SLC System provides backup capability for reactivity control independent of normal reactivity control provisions provided by the control rods. The OPERABILITY of the SLC System is based on the conditions of the borated solution in the storage tank and the availability of a flow path to the RPV, including the OPERABILITY of the pumps and valves. Two SLC subsystems are required to be OPERABLE; each contains an OPERABLE pump, an explosive valve, and associated piping, valves, and instruments and controls to ensure an OPERABLE flow path.

APPLICABILITY In MODES 1 and 2, shutdown capability is required. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate controls to ensure that the reactor remains subcritical. In MODE 5, only a single control rod can be withdrawn from a core cell containing fuel assemblies. Demonstration of adequate SDM (LCO 3.1.1, "SHUTDOWN MARGIN (SDM)") ensures that the reactor will not become critical.

Therefore, the SLC System is not required to be OPERABLE when only a single control rod can be withdrawn.

ACTIONS A.1 If the boron solution concentration is less than the required limits for mitigation but greater than the concentration required for cold shutdown (original licensing basis), the concentration must be restored to within limits in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . It is not necessary under these conditions to enter Condition C for both SLC subsystems inoperable since they are capable of performing their original design basis function. Because of the low probability of an event and the fact that the SLC System capability still exists for vessel injection under these conditions, the allowed Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is acceptable and provides adequate time to restore concentration to within limits.

The second Completion Timc for Required Action A.1 establishes a limit on the maximum time allowod for any combination of concentration out otf limits or inop;rable SLC subsystems during any single contiguous ocurrenec of failing to meet the LCO. If Condition A is entercd while, for instance, an SLC subsystem is inoperable and that subsystem is subsequently returned the OP2ERABLE, the LCO m-ay aready have been not met for up to 7 days. This situation could lead to a total duration of 10 days (7 days in Condition B, followed by 3 days in Condition A), since initial failure of the Ion, to reStore the SLC System. Ther an SLC subsystem could be found inoperable again, and concentration could be restored to within limits. This could continue indefinitely.

BWRISTSB 3..7- Rev 3.0 03/1/0 BWR/4 STS B 3.1.7-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 SLC System B 3.1.7 BASES ACTIONS (continued)

'n' 60f~UMnIRVAin WPAmiiinW' Mr AM n~rAnt AM :A VnR . nRAMAI. "SIMn -

7ArrMI-.-

. .- 9^;,,, , '

'r- II- - -_ AI -I~t+ - nA 1n-l^.-I __r 11; - --- r+hlrhr

,- -- h for beginning the a~lowed outago time "clock," FeGutingO in establiching the "time zero" at thc timc thc LCO was initially not met instcad of at the timc Condition A was onterod. Tho 10 day Complotion Time is an acceptablo limitation on this potcntial to fail to mect thc ILCO indefinitely.

B.1 If one SLC subsystem is inoperable for reasons other than Condition A, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE subsystem is adequate to perform the shutdown function. However, the overall reliability is reduced because a single failure in the remaining OPERABLE subsystem could result in reduced SLC System shutdown capability. The 7 day Completion Time is based on the availability of an OPERABLE subsystem capable of performing the intended SLC System function and the low probability of a Design Basis Accident (DBA) or severe transient occurring concurrent with the failure of the Control Rod Drive (CRD)

System to shut down the plant.

_._ _ r__ r_ - ----- -- ^ -'--- ' '

no Fecond GompIetion Timc bfr Pequired Action B.1 ecstablishes a limit on the maximum time allowed forany combinatioR of conentratin ou-t o f limits or inoporablo SLC cubsystoms during any singlo cEontiguous ocurrence of failing to mneet the ILCO. if Condition B is entered while, for instance, concentrationis out of limits, and is cubsequently roturnod to within limits,the LGO mnay already hae been not mnet for Up to 3 days.

This cituatien could load to a total duration of 1 0 days (3 dayci CoAdition A followod by 7 days in CoRdition B), QinRo initial failUro of the LCO, to rcstore the SLC System. Then concentrationcould be found out of limits agair, and the S1C 6rb eytom could be eretrord to OP AB LE.

This could continue indefinitely.

This Complotion Timo alloeS for an oxcoption to the normal "timo Zoro" for beginning the allowed outage time "clocs,"rcsulting in ecstablishing the "irno *Zro" at tho time the ICO wasc initiallyRnt met inctoad of at the timo Cnnditinn B wa' Pntcr'rd Thc 10 dav Cpmnlntinn Timc isan :c;nnt:i;h limittion slimitsato onh- on thi this peenia rrptnta!to fasssil to tovfai! to moo Fne tho th LCO I=G inofni-toly.

indfiiteWv_ llyig.

Rev. 3.0, 03/31/04 B 3.1.7-3 BWR/4 BWR/4 STS STS B 3.1.7-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

If, at any time during the existence of this Condition (one offsite circuit inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering no offsite power to one 4160 V ESF bus of the onsite Class 1E Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with any other ESF bus that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

The cecond Complotien Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power couFces to be inopreabcl during any Gingle contiguouS occurrne o failing to meet the LCO. If Condition A is entered while, for instance, a Mr, is inoncrahlIr and that DG is R1ubhScuntl'.' returned OPERABLE. the.

I PNrn% _Iots h-ao hoo rns rrar M, bar tn 74 lonwr T o+ _- -~

LCO may already have been not met for Up to 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation Gould lead to a total of 111 hEurs, since initial failure to meet the LCO, to restore the ffsite circluit. At this time, a DG gculd again become Rev. 3.0, 03/31/04 STS B 3.8.1-6 BWR/4 STS BWR14 B 3.8.1-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) inoperable, theo crcuit rostorod OPERA.BLE, and an additional 72_ hourr (for a total of 9 days) allowed prior to complete restoration of the LCO.

Th. 6 day Gomp.etion Time provides a limit on thc timc allowod in a specified condition after dicovery of failuro to moot the LCO. This limit is considered reasonabic for situations in which Conditions A and B arc Rontoed concurrently. The "AND" connetor between thc 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 day Completion Times means that both Completion Times apply simultancously, and the morM recStrictive Completin Timo must be met.

As in Required Action A.2, the Completion Timo allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception recults in ertablishing the "time zero" at the time the LCO was initially not met, instead of at the time that Condition A was entered.

B.1 To ensure a highly reliable power source remains with one DG inoperable, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included). Redundant required features failures consist of inoperable features associated with a division redundant to the division that has an inoperable DG.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal 'time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. An inoperable DG exists and

b. A required feature on the other division (Division 1 or 2) is inoperable.

BWR/STSB 3..1- Rev 3.0 0311/0 BWR/4 STS B 3.8.1-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In Condition B, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

The 6econd Complotion Timo for Required Action 8.4 oetablichoe a limit on the maximum time allowed for any combination of required AC powor coGuFrc to be inoperable during any single contiguoeu occurrence O failing to moot the LCO. If Condition B is entered whilo, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already haave boon not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This situation could lead to a total of 111 hourM, since initial failure of the ICo, to reutorn the DG. At this timeo an offfite GiFGcUit could againr becomo inoperablo, the DG roctorod OPERABLE, and an additional 72 hoUrF (foFr a total of 9 days) allewed pr6or to cmlete restoration of the LCO. The 6 day Completion Timo proFidoc a limit on the time allowed in a spccified condition after dicoere; of failure to mpeet the ICo. This limit is considered reasonable for situatien_ in which Conditions A and B arc entered concurrently. The "ANDI" conRector between theO72 hour and 6 day Completion Times mneans that both Completion Times apply cimultaneously, and the more rectrictive must be met.

As in Required Action 8.2, the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at the time that the LCO was initially not met, instead of the time that Condition B was entered.

C.1 and C.2 Required Action C.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with inoperability of two offsite circuits. Required Action C.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced B 3.8.1-9 Rev. 3.0, 03/31/04 BWR/4 STS BWR/4 STS B 3.8.1-9 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Condition A worst scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit, and on restoring power to the affected division. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because:

a. There is a potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit.

b. The potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP).")

The second Completion Time for Required Action A.1 establishes a limit oR the maximum timre allowed fo r nF combination Ofequired of r istibtion 61:113ystems to be inepeFable during any single Gontiguous occuFrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently returned OPERABLE, this LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ThiS situatioR could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the AC distributioR system. At this time a D circuit could aga-n become inoperable, and AC distribution could be restored OPERABLE.

This could continue indefinitely.

This Cempletion Time allws for an exception to the Refnral "time zero" for beginning the allowed outage time "clock." This results in establishing the "time zero" at the time this LCO was initially not met, instead of at the time Condition A '.was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months mpletin Timis acceptable limitation on this potential to fail to meet the LCO indefinitely.

Rev. 3.0, 03/31/04 STS B 3.8.9-4 BWRI4 BWR/4 STS B 3.8.9-4 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without adequate vital AC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions to restore power to the affected division, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

The sccond Complctien Time for ReqUirAd Action B.1 cstablishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrencc of failing to mccet the ICOQ. if Condition B,is entcrcd while, for iRStaRcc, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may akready have been not met for Up to 8 hourS. This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the vital bus distribution system. At this timre an AC division could again become inoperable, and vital bus distribution could be restored OPERABLE. This could continue indefinitely. ]

This Completion Time allowS for an exception to the normal "time Zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time that the LCO was initially not met, instead of at the time that Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.]

CA With one or more station service DC bus or distribution panel inoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution subsystem is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buses and distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

B 3.8.9-6 Rev. 3.0, 03/31/04 BWR/4 STS BWRI4 STS B 3.8.9-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Condition C represents one or more DC buses or distribution panels without adequate DC power, potentially with both the battery significantly degraded and the associated charger nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all DC power.

It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue,

b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division,

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

Thoe 6cond ComplotinR Timeor Required Acton C.1 establishesoa limit on the maximum time allowed for any combination of required distribution subsystems to be ioper^^ble dring any ciRglo contiguous eoccurrrne of failing to meet the LCO. If Condition C is cnteed while, for instance, an AC bus is inRoep erl and subscequRtly restored OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to rcstore the DG distributioR system. At this time, on AC diyisi.ein ceuld again become inoperable, and DC distribution could be restored OPERABLE. This could continuc indefinritly.

..- Rv .,0/10 BWI T BWR/4 STS B 3.8.9-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Thic Completion Time allowev for anR exception to the rmFrnal "trme zero-"

for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the tire thc LCO was initially not mnet, instead of at the time Condition C was ontered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation oR this pae-tial of failing to mt thc LGO indefin4ely-.

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 With one or more DG DC buses inoperable, the associated DG(s) may be incapable of performing their intended functions. In this situation the DG(s) must be immediately declared inoperable. This action also requires entry into applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating."

F.1 Condition F corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

Rev. 3.0, 03/31/04 STS B 3.8.9-8 BWRI4 BWR14 STS B 3.8.9-8 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ." Example 1.3 3 illustrates onc use of this type of Completion Tm.e The 10 day Completion Time cpccified for Conditions A-and B in Example 1.3 3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

1.3-2 Rev. 3.0, 03/31/04 BWRI6 STS BWR/6 STS 1.3-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X subsystem to subsystem OPERABLE status. AND inoperable.

10 days from discovery of failure to meet the LCO B. One B.1 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y subsystem to subsystem OPERABLE status. AND inoperable.

4v days49rM discovery of failure to meet the L__

C. One C.1 Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X subsystem to subsystem OPERABLE status.

inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months One subsystem to Function Y OPERABLE status.

subsystem inoperable.

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second 1.3-6 Rev. 3.0, 03/31/04 BWRI6 STS BWR/6 STS 1.3-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued) subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of ConditionsGA and B are modified by a logical connecter with a separate 10 doo Completion Time mneasured f{rom the time it was discovcred the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovey' of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "c lGo9k." In this iRstaRne, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the timne the aSSOciated Condition was entered.

INSERToroeiiasae n+tr 1.3-7 Rev. 3.0, 03/31/04 BWRI6 STS BWR/6 STS 1.3-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [ Concentration of boron A.1 Restore concentration of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in solution not within boron in solution to within limits but > [1. limits. AND 10 days from discovery of failure to meet the-CO ]

B. One SLC subsystem B.1 Restore SLC subsystem to 7 days inoperable [for reasons OPERABLE status.

other than Condition A]. AND 4 ordays fmm discovery of fai!ure to mneet the LGOJ C. Two SLC subsystems C.1 Restore one SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable [for reasons subsystem to OPERABLE other than Condition A]. status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

BWR/6 STS 3.1 .7-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no offsite available inoperable when power to one division the redundant required concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)

AND A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power AND 6 days from discovery of failure to meet LCO B. One [required] DG B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE [required]

offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s), 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG, inoperable when the Condition B redundant required concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)

AND BWR/6 STS 3.8.1-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.3.1 Determine OPERABLE [24] hours DG(s) are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s).

AND 8.4 Restore required DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AN4 6 days from discovery of failurc to meet LCO C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when the discovery of redundant required Condition C feature(s) are inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

BWR/6 STS 3.8.1-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 [Division 1], [Division 2], and [Division 3] AC, DC, [and AC vital bus]

electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more [Division 1 -- ------ NOTE------

and 2] AC electrical Enter applicable Conditions and power distribution Required Actions of LCO 3.8.4, "DC subsystems inoperable. Sources - Operating," for DC divisions made inoperable by inoperable power distribution subsystems.

A.1 Restore [Division 1 and 2] 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AC electrical power distribution subsystem(s) to AND OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failurc to meet tLG B. [One or more [Division I B.1 Restore [Division 1 and 2] 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 2] AC vital buses AC vital bus distribution inoperable. subsystem(s) to AND OPERABLE status.

46 hours5.324074e-4 days 0.0128 hours 7.60582e-5 weeks 1.7503e-5 months from discovery of failurc to meet tGG ]

BWR/6 STS 3.8.9-1 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more [Division 1 C.1 Restore [Division 1 and 2] 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 2] DC electrical DC electrical power power distribution distribution subsystem(s) to AND subsystems inoperable. OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LGQ D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. One or more [Division 3] E.1 Declare High Pressure Immediately AC, DC, or AC vital bus Core Spray System [and electrical power 2C Standby Service Water distribution subsystems System] inoperable.

inoperable.

F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, [and AC vital bus] electrical power distribution subsystems.

BWR/6 STS 3.8.9-2 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 SLC System B 3.1.7 BASES LCO The OPERABILITY of the SLC System provides backup capability for reactivity control, independent of normal reactivity control provisions provided by the control rods. The OPERABILITY of the SLC System is based on the conditions of the borated solution in the storage tank and the availability of a flow path to the RPV, including the OPERABILITY of the pumps and valves. Two SLC subsystems are required to be OPERABLE, each containing an OPERABLE pump, an explosive valve and associated piping, valves, and instruments and controls to ensure an OPERABLE flow path.

APPLICABILITY In MODES 1 and 2, shutdown capability is required. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate controls to ensure the reactor remains subcritical. In MODE 5, only a single control rod can be withdrawn from a core cell containing fuel assemblies. Demonstration of adequate SDM (LCO 3.1.1, "SHUTDOWN MARGIN (SDM)") ensures that the reactor will not become critical.

Therefore, the SLC System is not required to be OPERABLE during these conditions, when only a single control rod can be withdrawn.

ACTIONS A.1 If the boron solution concentration is less than the required limits for ATWS mitigation but greater than the concentration required for cold shutdown (original licensing basis), the concentration must be restored to within limits in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . It is not necessary under these conditions to enter Condition C for both SLC subsystems inoperable, since they are capable of performing their original design basis function. Because of the low probability of an ATWS event and that the SLC System capability still exists for vessel injection under these conditions, the allowed Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is acceptable and provides adequate time to restore concentration to within limits.

The second Completion Timc- for Required Action A.1 establishes a limit oR the maximum time allowed for an,' cornbinatiOn of concntration out pf limits or inoperable SLC 6ubsystems during any single contiguouc occurFlrcn of failingoF t m* t the OIG.

If CoRdition A is entered while, for inRtanrnR

.--Pn 1 C riihrvrtnm J - . - . . ir. innomorbln

-. and thmt rwhrbwtnm i'1 cubsequently

.. VV- -- I- -Vs -

Us1- __ _V Feturncd to -IIOPEiRABLE, A - "I-F w__s the LCO- - mnay already have been Ba _ . --- ok-. -vv I-- - VG not met for up to 7 days. This situation could lead to a total duration of 10 days (7 days in Condition B, followed by 3 days in Condition A), sinRe initial failUre of the LCo, to rFestre the SLC Syctem. Then an SLC cubsystem could be found inoperable again, and concentration could be restored to within limits. This could continue indefinitely.

Rev. 3.0, 03/31/04 B3.1.7-2 BWR/6 STS STS B 3.1.7^2 Rev. 3.0, 03131/04

TSTF-439, Rev. 2 SLC System B 3.1.7 BASES ACTIONS (continued)

This Completion Time allows for an exception to the norMal "time zero" for beginning the allowed outage time "clock", resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition was entered. The 10 day Completion Time is an aGceptable limitation on this potential to fail to meet the LCO indefinitely'.

B.1 If one SLC System subsystem is inoperable for reasons other than Condition A, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE subsystem is adequate to perform the shutdown function. However, the overall reliability is reduced because a single failure in the remaining OPERABLE subsystem could result in reduced SLC System shutdown capability. The 7 day Completion Time is based on the availability of an OPERABLE subsystem capable of performing the intended SLC System function and the low probability of a Design Basis Accident (DBA) or severe transient occurring concurrent with the failure of the Control Rod Drive System to shut down the plant.

The second Completioni Time for Required ActioR BA establishes a li~mit en the maximum time allowed for any combination of concentration out of limits or inoperable SLC subsystems during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, concentration is out of limits, and is subsequently returned to within liits, the LCO may already have been not met of up to 3 days.

This situation could lead to a total duration of 10 days (3 days in Condition A, follewed by 7 dayc in Condition B), since initial failure of the LCO, to restore the SLC System. Then concentration could be found out of limits again, and the SLC cubsystm -could be restored to OPERA\BLE.

This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clok", resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered. The 10 day Cempletion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

Rev. 3.0, 03/31/04 B 3.1.7-3 BWR/6 STS STS B 3.1.7-3 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This Completion Time assumes sufficient offsite power remains to power the minimum loads needed to respond to analyzed events. In the event more than one division is without offsite power, this assumption is not met. Therefore, the optional Completion Time is specified. Should two or more divisions be affected, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is conservative with respect to the Regulatory Guide assumptions supporting a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for both offsite circuits inoperable. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E distribution system.

The Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

The third Completion Time for Required Action A.3 establishes a limit on 1_- _..-.. _II..A Z:-_

SA_ __.A- _RA sBA*s A o A.A inR mFalamu FIUF ziiiaulwuu __ any vUMBiRmn9H HroUir v aOWe_

sources to be inoperable during any single contiguous occurrence ot failing to moot tho LCO. If Condition A is ontorod while, for inRcncR, a DG iB inoperable and that DG is subsequently returned OPERABLE, the LCO rany already haye been not met for Up to 72 horUS. This situatien could load to a total of 111 hours0.00128 days 0.0308 hours 1.835317e-4 weeks 4.22355e-5 months , 6inco initial failure to meet the LCO, to restere the effite circuit At thi time , a Dn could again become inoperable, tho circuit rctoered OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for a total of 0 days) allowed prior to complete restoration of the LCO.

The 6 day Compleo..n Time proyides a limit onrthe time allowe.cd in a specified condition after diccovery of failure to meet the LCO. This limit is Rev. 3.0, 03/31/04 B 3.8.1-6 BWR/6 STS BWR/6 STS B 3.8.1-6 Rev. 3.0, 03131/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

(considered reasonable for situations in which Conditionc A and B a3e enterod coRnurrently. The "AND" connectWor h the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and vbo.ee 6 day Completion Times means that both Completion Times apply cimultaneuouly, and the mnror roFtrictive muct be met.

As in Required Action A.2. the Completion Time allows for an exceptioR to thenorma8l "time vero" for beginniRg the allowed outage time "clock."

This exception results in establishing the "time zero" at the time the LCO wa initially Rnot mnet, intead of at the time that Condiltor A war, eRtered B.1 To ensure a highly reliable power source remains, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable.

Upon offsite circuit inoperability, additional Conditions must then be entered.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included, although for this Required Action, Division 3 is considered redundant to Division 1 and 2 Emergency Core Cooling Systems (ECCS)). Redundant required features failures consist of inoperable features associated with a division redundant to the division that has an inoperable DG.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists and

b. A required feature on another division is inoperable.

BWR/STSB 3..1- Rev 3.0 03/1/0 BWR/6 STS B 3.8.1-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In Condition B, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E distribution system. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

Tho second Complotien Time for Requirod Action B.4 established a limit on the maxmur timo allowed for aRy combinatieR Of rFequiFred AC poweF sources to be inoperable during any singlc contiguous occurrence of failin;g t mFeat the ICr. If oRditioRnB AReteresd while, for instanre, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 7-2 hours.

1--t 4- -n AA r #-rl l4rt tnttf1 t : --- no~

-;t;-I T_;l- 4-t II Tl: ---.I 110Z1_ IUMv'II MMUUU llM' LUtv'ElUL UlM V I IlsIMIUUI, fI0 t Iik 'U. "I thU meet the LCO, to restore the DG. At this time, an offsite circuit could agaiR beeomne iRoperable, the G rIesteored OPERABLE, and ar additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 9 days) allowed prior to complete restoration of the LCO. The 6 day CompletioR Time provides a lrimt nR the time allowed in a specified condition after discovery of failure to meet the LCO. This limnit is oRsidered reasonRable for situatiR n;r Which Conditions A and B are entered eoncurrontly. The "AN D" conneGter between the 72 hore aRd 6 day Completion Times means that both CompletioR Times applyrcinmultanewusly, aRd the more rsrtricntie Completion Time must be met.

As in Required Action B.2, the Complotion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at the time the LCO was initially net met, iRnstead of the time Condition B was entered.

C.1 and C.2 Required Action C.1 addresses actions to be taken in the event of concurrent failure of redundant required features. Required Action C.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed with only one division without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, Rev. 3.0, 03/31/04 B 3.8.1-9 BWR/6 STS STS B 3.8.1-9 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

The Condition A worst scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit, and on restoring power to the affected division. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because:

a. There is potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit.

b. The potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP).")

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. if Condition A intntrd ientord we,hl for / tn, a DC bus is inoperable and subsequently returned OPERABLE, the LCO mayMC IE eUY MCI V UtiI Mri 1 #Idl t **U IdgJ _C. I 4 -. . vt -IM 'o M U iU lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , Since initial failure of the LCO, to roStOro the AC dirtribtiodn ycteom. At this time, a DC crcFuit could agaiR become inoperable, and AC distribution could be restored OPERABLE.

This ceuld oGntinue indefinitely.

Thiq r_ Cronmltion

..- s _v vM. Tamc grae

. nlnum

-M.-.V.f foir

-V an-mm cxrcction

- - XV thp MF#EV-to is1 normal 1111_-

DIE "time tilliU_ zero"

__ V for beginning the allowed outage time "clock." This rosults in eotablishing the "time; zero at the time the LCO met, intead of at the-M"ot time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable lim;itatien on this petential to fail to meet the LCQ indefinitely.

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC divisions made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a B 3.8.9-4 Rev. 3.0, 03/31/04 BWR/6 STS BWRI6 STS B 3.8.9-4 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action 8.1 ostablishes a limit oR the maximum time allowcd for anyesmbinatieR of reqUired diStributie subsystems to be inoperable during any single contiguous occurrencoe of fai~ing to meet the LGO. if Cndition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already havo boon not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Thi.s cituation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, for restoring the vital bus distribution system. At this time, an AC division could again become inoperable, and vital bus diStributioR could- b restored to OPERA.BLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allewed outage time "clock." This allowanc r esults ir establishing the "time zero" at the time the LCO was initially not met, instead of at the time that Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.]

C.1 With one or more Division 1 and 2 DC buses or distribution panels in one

[division] inoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystems could result in the minimum required ESF functions not being supported.

Therefore, the required DC buses and distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

BWR/6 STS B 3.8.9-6 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Condition C represents one or more DC buses or distribution panels without adequate DC power, potentially with both the battery significantly degraded and the associated charger nonfunctioning. In this situation, the plant is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the majority of components that could be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, that would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue,

b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Compiction Time for Required Action C.1 establishes a limit on the maximum ti-e allowed foraRy combination of reqUircd dictribution failing to mo**t the LCO. if Cendition C is entered while, for iVntaneo, an AC bub iss inopabl b and dubriqungtly itungedconRuoBLE, the LCO may already have been not met for up to 8 hourM. This situation could load to a total duration of 10 hoUMro, in iRitial failur of the LCO, to restore the DC distribution system. At this time, an AC division could again become inoperablc, and DG ditibution could be retored OPERABLE. This could continue indefinitely.

..- Rv .,0/10 BWI T BWR/6 STS B 3.8.9-7 Rev. 3.0, 03/31/04

TSTF-439, Rev. 2 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This Completion Time alovW for aR exccptien to the normnl "time co"e for beginning the allowed outage time "clock." This allowancc results in establiching the "time zero"at the time the ILCG was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Complction Time is an acccptablc limitation on this potential of failing to meet the

!O inderiR;tely.

D.1 and D.2 If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated Completion Times, the plant must be bought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 With the Division 3 electrical power distribution system inoperable, the Division 3 powered systems are not capable of performing their intended functions. Immediately declaring the high pressure core spray inoperable allows the ACTIONS of LCO 3.5.1, "ECCS - Operating," to apply appropriate limitations on continued reactor operation.

F.1 Condition F corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

(Single division systems are not included, although for this Action, Division 3 is considered redundant to Division 1 and 2 ECCS.) When two or more inoperable electrical power distribution subsystems result in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

BWR/6 STS B 3.8.9-8 Rev. 3.0, 03/31/04

TSTF439, Rev. 2 Attachment NRC Memos on Second Completion Time Issue

.A fnt n**0%nftt Dfll/lnf2

. ' 4US1 WORD nRoc. lU MUIl4CULQU Iwvirb U FRON: Gordon vytlkcil WINs 184-4155 DATE: Aust a, 11 SSICT: ay of potential Allowed Outage Time (ADT) extensio4 issue.

TO; TSP The potential AOT erteni INocturs When a Condition in a specification is entes, but, before the Co ltion Time for that Condition is passed, a second different Condition Is inter4 . Befare the Coiletion Tim for ths wCOnd Condtm1on is passed, the firnt Condition Is entered again.

lhu scenario described above could potmntielly allow opration of th plut, while not "etin#an LCO, to occur ind MtelyTo overcom this lssue, specifications that have met certain critria (e below) have Identified and fixed by an indvtry approved methods.

The following criteria were used to dtermirn it a speoificatian has been written in a way that would allow indeflnite plant operation with non*

compilance.

1. The ACTIONS table must contain mor than cone Condttion.

2. The Co"pletion Time(s) of the Conditions ust be longer than S. Required Actions which change the HOD= of the plant to outside the applicability cannot extend the ACT and, therefore, are not considered.

4. operation with *on-cpllan".

b1a Inrgt1nr w 'r lied to t e markup of NIREQG1431 owi"tng Westtnghoo Spec fications ir ide i.ed 3.6.6A Containment Spray and Cooling Sytm f 3.1.68 Contairnat Spray 4% tl1 X $M 3.6-10 H1droql Iglntlif Sstem 6t-'U4) 3.6.13 S iid BDuilding Air Clean p it ( t 3.7.4 Auxiliary FeWter Sys M71-1r 3.8.1 AC Sources - Operating '-" u wr) 3.8.9 Distribution Systes *- utdn ( '

iPcifications the following h s added In the Cplet1on Time Cal u cau'Iuxad the ADm: 30io dAyJ fro discovery of ilua q*1sion tTiCs cap found b odding tb atwo Condltionl that coud xtend the AT.. It ther are more than two Conditiws that can extend the AOT the Completion Time cap isfound bY adding the shortast Covplation Tim and the longest Completion Time. The brack*e are only to show that the 30 days is a specification dependent time 1

3.6 CDNTAiwIEN SYSTERS 3.6.I fo WI M Movl b theCOUO~dSpray System)

(Croit LCO 3.6.IA Iwo coitalwamft spray trains and M on ainmnt cooling

,trains 01Il bo OPCRADL 72 hom 8 swewlIOa ff to(

I1@o1 84 hourt I 7 days AM is 1472

- ~* jd

- D~6*4 I To wdaTA "

BlOG Mn 3.6-21 w oo Psrs

/ N/9 3821 l 5:03p m

FROM: Gordon M. Vytal Sas PHONE: (412) 374-4155 FAX: (412) 3744693 DATE: December 16, 1991

SUBJECT:

Infomiation on the Comnplion Time Cap - to be d=eussed at Wednesdays meng with Chls Grimes TO: Lee Bush, WOO Lee Robertson, BW1AOG Ban Woods, CEOG BlurWunderly, BWOG In July considerable work was done to address non-complance with oertain LCOs for an extended time. Ths letter wi seve as a rtrinder of the problem and the solution we ouwid.

Sone spoc;icatons allow entiy rnto a Condfon and bebre thf Completion Tim expqbes a different Condition hI the same speofficaton Is entered. Tho problem occurs when, previous to the expiration of the second Completion Time, th Wrs wondftion Is entered for a second time, this prooess could alow an LCO to neowr be met Multiple Condifton entry Is perrnisible, but, the repettive entry into the same Condon, 9o that the LCO In not met for an extended period of trme, Is unacceptable.

To prevent Ns, all the specifcations were soreened. Speifloions that had more than one non-shutdown Conditon with Completion Tmes longr tan 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months were studled to see If a Condition could be entered repetitively while the LCO was not met. The fIns WOO It contained seen specifoaons:

3.8-6A Containmnt Spray and Coding Systems 3.6.68 Containment Spray and Cooing Systems 3A10 Hydrogen Ignition System 3.8.13 Shield Building Ar Cleanup Sysm 3.7.4 Axliary Feedwater System 3.8.1 AC Sources - Operating 3.8.9 Dlstldbuton Sytems - Shutdown To cap thotme tat a plant would not be complying with an LCO, additional Completion mes were used. If a specification had only two Condions that could extend the AOT, the Completion linm for those Conditions were added snd tl surnmed Compleion Tim was inserted Into both Condlilons. See example A. Hf a specffcton had more thn two Conditions that could extend te AOT, the Inserted Completion lim was the sum of the longest and shortest Compleon TImes of all Conditions lnolved. See examrple B.

Due to the additional Completion lnmes Bases womrng was also developed although my notes do not indicate that wording was agreed upon.

i!

i ;,

i;-

sI

if you have questions on ft material I'll be In tomorrow until 4:00 at which point 111 be on my way to RockbM*.

nMAa spcceatison ProSaM O Attachments

O 3m 3.6 CMTAINWV(T SYSMS

¢)3.6. + SBACS (Dual an Icy Coentaer)

(D)LCO 3.6.i+ Two SACS trains shall be OPERLE (and all shield building access opeirg doors shall be closed].

AM~

ACT!

A.

8.

e C. RqIred Actioneand asuMclat CWltlon Tliinnot wt.

KDG MT 3.6-4 WOC S$ 3*6-4501/06/91 3:03pm

in 1(,pro'.

rapfe. ,A-n, c Le-0)

DieSel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 _il .SLQ+/-1 -

APPLICABILITY: When associated diesel generator Is required to be OPERABLE.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I

"a A. Fuel level < 60,0001 A.I Restort fuel oil level 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months gallons and - (51,4253 in D0storage tank.

gallons in storage tank. 2 B. Lubricating oil 9.1 Restore lube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months inventory C [se0] inventory.

gallons and > (4251 ,0 C. Stared fuel otl total C.1 Restart fuel oil 7 days particulates, particulates 4e&-w4t(

w F~~~~y/Z <0z g

0. New fuel o11 propertes D.1 Restore new fuel oil 30 days b not withij Jlimts of Dropertles to within SR 3.8.3.4 M1"ts. ;p 0 4 I __________________ -

(continued)

If Aii i, d 755 ,

'5'Z -S 1. .4 C.

, ;% 6-%:tV-- .

k I.,. i f I 3.6 rhkU 6/18/91

Diesel Fuel Oil ArTTflNq Ijnntintnarll.

CONDITION REQUIRED ACTION ICOMPLETION TIME E. Required Action and E.1 Diclare associated Innediately associated Completion diesel generator Tin of Condition A, 8, inoperable.

C, or D not mt.

QB Diesel fuel oil or lubricating oil not within limits for reasons other than Condition A, St C or D.

.9 SURVEILLANCE REQUIRDEHT SURVEILIlNCE FREQUENCY SR 3.8.3.1 Verify each fuel storaga tank contains 31 days 2 [ 60,000 I gallons of fual.

SR 3.8.3.2 Verify lubricating oil inventory is 31 days t SOO 3 gallons.

SR 3.8.5.3 Verify flash point, specific gravity, Once within viscosity, and appearance of new fuel are 31 days prior within limits when tested in accordance to addition of with applicable AMTh standards. new fuel to storage tank (continued) 3.8. 6/18/.1

TSTF-05-10, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco.

Contents

Text

SUBJECT:

Dear Sir or Madam:

Contact:

Description:

Description:

Description:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

SUBJECT:

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TSTF-05-10, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an Lco.

Text

SUBJECT:

Dear Sir or Madam:

Contact:

Description:

Description:

Description:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

SUBJECT:

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